Philadelphia, Baltimore & Washington Railroad v. Smith

Background

A camp cook who worked for a railroad brought suit under the Federal Employers’ Liability Act to recover for injuries he suffered on December 23, 1915. He was part of a gang of bridge carpenters’ helpers who lived, ate, and slept in a camp car the railroad furnished and moved along the line. The gang repaired bridges and abutments on the railroad near Easton, Maryland, and the cook’s duties were to keep the car clean, tend the beds, and prepare meals. While cooking in the camp car on a side track, a railroad engine struck the cars and injured him, and a Maryland court awarded him damages.

Reasoning

The Court’s core question was whether the cook was engaged in interstate commerce under the statute. The Court said bridge repairs are part of interstate commerce because they keep instrumentalities of interstate travel in operation. The cook was employed in the company camp car and moved to where the bridge gang worked to make their work possible and more efficient. Because he assisted the gang by keeping their lodging and meals close to the work, the Court treated his role as part of the bridge repair work and therefore part of interstate commerce, so the federal law applied and his recovery was proper.

Real world impact

The decision makes clear that workers who live and work in employer-provided mobile camps and who support tasks that serve interstate transportation can be covered by the federal employers’ liability law. It limits claims that such workers are only serving personal convenience when their employment advances the employer’s interstate operations. The judgment for the injured cook was affirmed.